Why Lithuania for Your Crypto Licence
Lithuania gives you a full EU passport from one of Europe’s deepest fintech ecosystems, at MiCA’s own capital minimums and without the national overlays that drive up cost elsewhere. A Lithuanian MiCA CASP authorisation lets you serve clients across all 30 EEA member states, and you secure it through a regulator that has supervised crypto businesses for years rather than one meeting them for the first time. That combination is why we build serviced licensing here.
The Bank of Lithuania has moved from quantity to quality gatekeeping. The tight fit-and-proper standards and the decisive weight placed on source-of-funds evidence mean applications with weak documentation fail hard, not slowly — which is precisely why we build every dossier to the standard that clears rather than hoping for leniency. Lithuania is fast and capital-efficient only if your structure and governance can stand the scrutiny; template compliance work kills applications here.
Lower locked capital, real banking rails. Lithuania applies MiCA’s own-funds minimums directly: €50,000 for Class 1, €125,000 for Class 2 and €150,000 for Class 3, with none of the national overlays Estonia stacks on top (€100,000–€250,000). It is also the EU’s most prolific EMI jurisdiction, with 70-plus licensed institutions and the central bank’s CENTROlink system giving direct SEPA and TARGET2 access, so a CASP handling fiat flows gets real settlement rails instead of a correspondent-banking scramble.
An experienced supervisor. Lithuania was the EU’s largest crypto jurisdiction by entity count before MiCA, and the Bank of Lithuania carries that supervisory history into the new regime. You are dealing with a regulator that knows the sector, which makes a well-prepared application move faster and a weak one fail sooner. We make sure yours is the former.
Which Business Models Suit Lithuania
Lithuania fits operators who want the broadest EU reach at the lowest sensible capital outlay. Before we file, we confirm your model maps cleanly onto the MiCA service classes and that the jurisdiction genuinely serves your plan.
- Exchanges and brokers seeking EU-wide reach. One Lithuanian licence passports trading, exchange and execution services across the EEA, so you sell into 30 markets from a single base.
- Custody and wallet providers. Class 2 custody authorisation pairs with Lithuania’s EMI and CENTROlink rails for the operational and safeguarding banking custody businesses need.
- Fintech and payment firms adding crypto. Lithuania’s EMI density makes it the natural home for payment operators bolting a CASP onto an existing model.
- Capital-conscious operators. MiCA minimums with no national overlay mean less idle capital than Estonia or most Western European options.
- × Profit-reinvestment plays. If retaining earnings tax-free is the priority, Estonia or Latvia (0% CIT on retained profits) may suit better. We will tell you straight.
- × English-only operations. Lithuanian is the primary regulatory language. We handle that for you in-country, but if you want English-language proceedings end to end, Malta is worth weighing.
- × Tokenised securities or RWA. A MiCA CASP licence does not cover financial instruments. Where your model needs it, we scope the MiFID securities route or EU fund licensing alongside crypto permissions.
What We Do for You
We deliver the licence, we do not hand you a shortlist and step back. From the first scoping call to the day your authorisation publishes, you deal with one accountable firm and our in-country specialists. We file the work and we stand behind it.
- Form your UAB. We incorporate your Lithuanian private limited company, deposit the required own-funds, appoint the management body, install a resident MLRO, and establish a genuine physical office that satisfies the Bank of Lithuania’s substance test.
- Build the compliance suite. We draft every policy bespoke to your model and to Lithuanian law: AML/CFT manual, enterprise-wide risk assessment, sanctions screening, transaction monitoring, Travel Rule implementation, KYC/KYB, the DORA ICT framework, complaints handling, conflicts of interest and wind-down plan. Generic templates are the single most common cause of rejection, so we do not use them.
- Prepare the people and the proof. We assemble fit-and-proper files for directors, officers and qualifying shareholders, including the source-of-funds and source-of-wealth evidence that decides most Lithuanian applications.
- File and manage the application. We submit through the LBIS portal, run pre-application engagement with the Newcomer Programme, and handle every regulator query and information request through to authorisation, in Lithuanian.
- Arrange banking. We open the two layers a CASP needs: an operational EMI account on CENTROlink and a credit-institution relationship for client-fund safeguarding under MiCA Article 70. We start this during the application so banking is ready when your licence is.
- Run ongoing compliance. After authorisation we set up reporting to the Bank of Lithuania and the FCIS, DAC8 obligations, and the annual cycle, so the licence stays in good standing.
We scope and quote each engagement to your specific model and service classes. Tell us what you are building and we will map your route to approval and price it.
Regulatory Framework
Lithuania regulates crypto-asset service providers under the EU’s Markets in Crypto-Assets Regulation (MiCA), Regulation (EU) 2023/1114, which applies directly without national transposition. The national implementing law is the Law on Markets in Crypto-Assets (No. XIV-2879), adopted by the Seimas in July 2024. The Bank of Lithuania is the sole competent authority for CASP authorisation, and crypto-asset services provided by Lithuanian CASPs are VAT-exempt under the CJEU Hedqvist ruling.
The authorisation is indefinite, with no renewal: you pay an annual supervision contribution and meet ongoing prudential, governance and conduct obligations. The current landscape is the product of deliberate tightening: Lithuania’s light-touch 2020 VASP regime drew 800-plus registrations, late-2022 amendments raised capital and substance requirements until the register fell to roughly 370, and the move to MiCA under the Bank of Lithuania completed the shift to a quality-over-quantity supervisor. A few overlaps also matter: e-money-token services can trigger PSD2 dual authorisation, equity-like or market-traded tokens fall under MiFID II rather than MiCA, and some AIFM activity needs an Article 60 notification. We classify your tokens and services against these lines before filing.
Licence Classes and What They Cover
MiCA defines 10 crypto-asset services grouped into three classes that set your capital tier: €50,000 for Class 1, €125,000 for Class 2 and €150,000 for Class 3. You hold authorisation for the specific services you intend to provide, and the combination decides the class. Most exchange and custody operators land in Class 2 or Class 3. We confirm the right class for your model before any capital is locked.
| Class | Service | MiCA Reference | What it covers |
|---|---|---|---|
| 1 | Reception and transmission of orders | Art. 3(1)(24) | Receiving client orders and routing them to another CASP or trading platform |
| 1 | Advice on crypto-assets | Art. 3(1)(25) | Personalised recommendations on crypto-asset transactions |
| 1 | Portfolio management | Art. 3(1)(26) | Discretionary management of client crypto-asset portfolios |
| 1 | Execution of orders on behalf of clients | Art. 3(1)(22) | Buying and selling crypto-assets per client instructions |
| 1 | Placing of crypto-assets | Art. 3(1)(23) | Marketing newly issued crypto-assets to investors |
| 1 | Transfer services on behalf of clients | Art. 3(1)(27) | Transferring crypto-assets between addresses for clients |
| 2 | Custody and administration | Art. 3(1)(17) | Safekeeping crypto-assets and private keys for clients |
| 2 | Exchange of crypto-assets for funds | Art. 3(1)(20) | Fiat-to-crypto and crypto-to-fiat conversion |
| 2 | Exchange of crypto-assets for other crypto-assets | Art. 3(1)(21) | Crypto-to-crypto conversion |
| 3 | Operation of a trading platform | Art. 3(1)(18) | Operating an exchange matching buy and sell orders |
Some activity sits outside MiCA entirely: fully decentralised services with no intermediary, genuinely unique NFTs (unless issued in large series, fractionalised or functioning as payment or investment instruments), CBDCs, deposits and insurance products. Tokenised securities and RWA that meet the financial-instrument test follow MiFID II, the Prospectus Regulation and the EU DLT Pilot Regime, not MiCA. We map your activity to the correct perimeter so you are neither under-licensed nor over-licensed.
What the Bank of Lithuania Requires
A Lithuanian CASP needs a UAB, own-funds of €50,000–€150,000 by service class, a genuine physical office, a Lithuanian-resident MLRO, a natural-person management body and a bespoke compliance suite. Every qualifying shareholder holding 10% or more undergoes fit-and-proper assessment. The binding constraints are capital, real substance and documentation quality: applications fail on weak source-of-funds evidence and recycled templates, not on the complexity of the rules. We prepare each of these to the standard that clears.
| Requirement | Detail |
|---|---|
| Entity type | UAB (Uždaroji Akcinė Bendrovė, Private Limited Company) |
| Minimum own-funds (Class 1) | €50,000 |
| Minimum own-funds (Class 2) | €125,000 |
| Minimum own-funds (Class 3) | €150,000 |
| Ongoing own-funds formula | Higher of: permanent minimum per class OR 25% of fixed overheads of the preceding year |
| Management body | One natural person minimum (single-person manager, vadovas); corporate directors not permitted; regulators expect at least two effective directors under the four-eyes principle (supervisory, not statutory) |
| MLRO | Lithuanian resident required; employment contract mandatory |
| Senior management EU residency | At least 1 member of senior management must be EU resident |
| Physical office | Registered office in Lithuania; virtual offices not accepted |
| Foreign ownership | 100% foreign ownership permitted |
| Qualifying shareholders | All holders of 10%+ capital/voting rights undergo fit-and-proper assessment with source-of-funds verification |
| PI insurance | Not specifically required; own-funds are the primary prudential safeguard |
Fit-and-proper and source of funds
The Bank of Lithuania assesses directors, senior managers, qualifying shareholders and key function holders for qualifications, integrity (criminal and regulatory history) and financial soundness. The decisive element is source of funds and source of wealth for owners holding 10% or more: this is where most early applications collapsed. We build these files properly, with the tax returns, bank records and employment history that stand up to scrutiny rather than a certificate of deposit on its own.
Real substance, not a letterbox
Lithuania requires genuine local substance. A physical registered office is mandatory and virtual offices are rejected. The MLRO must be a Lithuanian resident on an employment contract, and at least one senior manager must be EU-resident. The regulator checks that the structure can actually be supervised from Lithuania. We establish the office, place the resident MLRO and structure the management body so the substance test is met, not finessed.
AML/CFT, sanctions and the Travel Rule
The AML framework runs under the Law on the Prevention of Money Laundering and Terrorist Financing, with the EU Transfer of Funds Regulation Recast applying directly. There is no de minimis threshold for CASP-to-CASP transfers: full originator and beneficiary information must accompany every transfer. The €1,000 threshold applies only to self-hosted wallets, where ownership of the address must be verified above that figure. Screening must cover EU and UN sanctions lists, and suspicious transactions are reported to the FCIS through goAML within three working hours for suspended transactions. We build all of this into your compliance suite and reporting set-up.
Application Process and Timeline
The realistic end-to-end timeline is 4–8 months. The Bank of Lithuania has up to 25 working days to check completeness and 40–60 working days for substantive assessment; most of the calendar time before that is preparation, which cannot be rushed with off-the-shelf templates. The first Lithuanian CASP was authorised in roughly five months, so a well-prepared application reaches the lower end of the range. We run the whole sequence and keep the regulator’s clock moving.
Stage 1 2–6 weeks
We form your UAB and deposit capital
We incorporate the UAB through the Register of Legal Entities (see our Lithuania company formation service), deposit the €50,000–€150,000 own-funds, appoint the management body and resident MLRO, and establish the physical office.
Stage 2 6–10 weeks
We build the compliance suite
We draft the full bespoke documentation set under MiCA Article 62 and the related RTS, plus your programme of operations and three-year projections. This is the work that wins or loses the application, and it cannot be templated.
Stage 3 2–4 weeks (parallel)
We open banking
We arrange the operational EMI account and the credit-institution safeguarding account MiCA Article 70 demands. We run this in parallel so banking is not a bottleneck at authorisation.
Stage 4 1–2 weeks
We run pre-application engagement
We present your business model and governance to the Bank of Lithuania’s Newcomer Programme for early feedback, surfacing and fixing issues before the statutory clock starts.
Stage 5 1 week
We file
We submit the complete application and annexes through the LBIS portal in Lithuanian and pay the state application fee.
Stage 6 40–60 working days
We manage assessment to a decision
We handle the completeness check and every information request through substantive assessment. On authorisation, your licence is published in the Lithuanian register and notified to ESMA for the EU-wide register.
Taxation
Lithuania is a moderate-tax EU jurisdiction. The standard corporate income tax rate rose to 17% on 1 January 2026 (from 16%, and 15% before that) under a defence funding package, with a reduced 7% rate for qualifying small companies and 0% for the first two periods of a new small company. Crypto-asset exchange services (fiat-to-crypto) are VAT-exempt under the CJEU Hedqvist ruling. We structure your entity to use the reliefs it qualifies for.
| Tax | Rate | Crypto Application |
|---|---|---|
| Corporate income tax | 17% (standard, from January 2026) | All CASP profits |
| Small company rate | 7% (revenue ≤ €300,000, from January 2026) | Available if CASP qualifies; 0% for first 2 taxable periods of new companies |
| Capital gains (corporate) | 17% (part of CIT) | Gains from crypto trading by corporate entities |
| Capital gains (individual) | 15% (20% above ~€277,458) | €2,500 non-taxable annual allowance for personal asset sales |
| VAT | 21% standard; crypto exchange VAT-exempt | Fiat-to-crypto exchange exempt per Hedqvist ruling |
| Dividend withholding (to companies) | 17% | Exempt if ≥10% holding for ≥12 months (participation exemption) |
| Dividend withholding (to individuals) | 15% | Withheld at source |
| Interest withholding | 0% (EEA/DTT) / 10% | Depends on recipient jurisdiction |
| Employer social contributions | 1.77%–2.49% | On gross salary; employee pays ~19.5% |
Incentives worth structuring around
Beyond the headline rate, Lithuania has reliefs we routinely use. Its Free Economic Zones offer 0% CIT for ten years and a 50% reduction for six more on qualifying investments; R&D spend earns a triple deduction; and qualifying IP income sits in a 7% patent-box regime. On the reporting side, DAC8 data collection starts from 1 January 2026 with first reporting due 30 September 2027, and CARF follows from 2027. The OECD global minimum tax only bites on groups above €750m of revenue, which rarely touches a standalone CASP.
Ongoing Compliance and DORA
The authorisation is indefinite, but supervision is active. CASPs file annual audited financial statements, capital-adequacy and activity reports to the Bank of Lithuania, report AML/CFT matters to the FCIS, and pay an annual supervision contribution rather than a renewal fee. Both regulators run scheduled and unscheduled inspections covering AML/CFT, client-asset segregation, cybersecurity and governance. Enforcement is real: fines reach €5,000,000 or 12.5% of turnover for the entity, up to €700,000 for individuals, alongside public statements, business restrictions and withdrawal of authorisation. Marketing must be fair, clear and not misleading, and Google has required valid CASP authorisation for EU crypto advertising since April 2025. We set up the reporting calendar and keep your licence in good standing.
DORA and ICT resilience
The Digital Operational Resilience Act applies to every MiCA CASP and has done since 17 January 2025, with the Bank of Lithuania as enforcer. It sets five pillars: ICT risk management, incident reporting, resilience testing, third-party ICT risk, and information sharing. Major incidents must be reported on a tight clock: an initial notification within 4 hours of classification (and no later than 24 hours after becoming aware), an intermediate report at 72 hours, and a final report within a month. All CASPs run general vulnerability and penetration testing; only entities the regulator designates as significant face threat-led penetration testing, at least every three years. Custody operators must run segregated hot and cold wallet architecture with multi-signature controls and documented key management. We build the DORA framework into your application and operationalise it after.
Banking
Banking is the constraint that turns a Lithuanian licence into a working business, and it is part of what we deliver. MiCA Article 70 requires client funds to be held with a licensed credit institution, not an EMI, in a segregated account by the end of the next business day. That means two layers: an operational account for day-to-day flows and a credit-institution relationship for safeguarding.
For operational flows, Lithuania’s position as the EU’s densest EMI market helps: institutions connected to CENTROlink, the central-bank payment system, give direct SEPA and TARGET2 access without leaning on correspondent banking. The harder account is the safeguarding relationship with a credit institution, where due diligence is thorough and can run two to four months. We open and drive these conversations during the application phase, alongside the filing, so banking lands when your licence does. We hold the institutional relationships directly and put them to work for you.
International Standing and EU Passporting
Lithuania is a clean jurisdiction to license from. It has never appeared on any FATF list, and as an EU member state it falls outside the EU list of high-risk third countries entirely. Its AML framework is assessed by MONEYVAL, the Council of Europe’s regional body, which completed Lithuania’s fifth-round process at the end of 2024; it now awaits its sixth-round evaluation and rates Compliant or Largely Compliant on 36 of the 40 FATF Recommendations. The transfer of crypto supervision to the Bank of Lithuania under MiCA is the direct response to earlier criticism of the old VASP regime.
The commercial heart of the licence is the passport. Under MiCA Article 65, a single notification to the Bank of Lithuania lets you provide services cross-border and open branches across all 30 EEA member states, with no extra authorisation, capital or waiting period from host regulators. Iceland, Liechtenstein and Norway sit inside the passport through the relevant EEA Joint Committee Decision; the United Kingdom, Switzerland and Gibraltar sit outside it and need local authorisation for local clients. Reverse solicitation is a narrow third-country pathway and is not a substitute for passporting within the EEA. We file the passporting notifications for the markets you intend to serve and keep the perimeter clean.
How Lithuania Compares
Lithuania competes directly with Estonia (the Baltic digital pioneer), Latvia (the cost-conscious alternative), Poland (the CEE market weight), and Malta (the established crypto centre). Each offers MiCA passporting, the key differentiator is cost, timeline, tax, and regulatory maturity.
| Factor | Lithuania | Estonia | Latvia | Poland | Malta |
|---|---|---|---|---|---|
| Licence Type | MiCA CASP | MiCA CASP | MiCA CASP | MiCA CASP | MiCA CASP |
| Regulator | Bank of Lithuania | Finantsinspektsioon (FSA) | Latvijas Banka | KNF | MFSA |
| Timeline | 4–8 months | 3–5 months | 3–9 months | Not operational | 9–18 months |
| Min. Capital | €50,000–€150,000 | €100,000–€250,000 (national overlay) | €50,000–€150,000 | €50,000–€150,000 (proposed) | €50,000–€150,000 |
| Corporate Tax | 17% standard / 7% small | 0% retained / 22% distributed | 0% retained / 20% distributed | 19% / 9% small | ~5% effective (refund system) |
| Local Presence | Office, resident MLRO, 1+ director (2 expected in practice) | Office, 2+ directors, compliance officer | Office, 1+ director, compliance officer | Office, 2+ directors (proposed) | Office, 2+ directors, company secretary |
| EU Passporting | Yes | Yes | Yes | No (legislation blocked) | Yes |
| FATF / MONEYVAL status | Not FATF-listed; MONEYVAL 5th round complete (Dec 2024) | MONEYVAL: Enhanced Follow-Up | MONEYVAL: 6th round MER (June 2025) | MONEYVAL: Enhanced Follow-Up | Not FATF-listed; grey-list exit (June 2022) |
| Best For | Cost-conscious operators; EU access; fintech ecosystem | Tech-first companies reinvesting profits (0% CIT); e-Residency | Startups; lowest-cost EU entry; supportive regulator | As of April 2026, unsuitable (no MiCA implementation) | Established exchanges; English-language operations |
The key difference: Lithuania and Latvia both apply MiCA capital minimums directly, while Estonia layers higher national overlays on top. Lithuania’s edge over Latvia is its deeper fintech ecosystem and longer crypto supervisory track record; its trade-off against both is the 17% CIT, since companies reinvesting profits pay 0% in Estonia and Latvia. Poland, after two presidential vetoes, still has no MiCA-implementing legislation and no CASP licensing route, so Polish firms are relocating to the Baltics. We deliver crypto licensing in Estonia, Latvia and the Czech Republic too, so if another jurisdiction fits your model better, we will tell you and file there instead.
Reinvesting profits? Consider Estonia
Estonia’s MiCA CASP authorisation pairs full EU passporting with 0% corporate tax on retained profits, which can suit growth-stage operators better. We deliver it directly.
Frequently Asked Questions
What does Tomberg & Partners actually do for a Lithuanian CASP licence?
We deliver the whole licence and stand behind it. We form your UAB, deposit the capital, appoint the management body and resident MLRO, build the full bespoke compliance suite, file with the Bank of Lithuania through the LBIS portal, and manage every regulator query through to authorisation. We arrange both layers of banking and set up your ongoing reporting. You deal with one accountable firm and our in-country specialists, not a chain of intermediaries. Contact us and we will scope and quote your case.
How much does it cost?
It depends on your service classes, structure and complexity, so we scope each engagement and quote it rather than publish a number. Capital is set by MiCA and locked in your own company: €50,000 for Class 1, €125,000 for Class 2 and €150,000 for Class 3. The Bank of Lithuania also charges a state application fee. Tell us what you are building for a quote.
What type of company is required for a Lithuanian CASP licence?
A UAB (Uždaroji Akcinė Bendrovė, a private limited company) is the required entity, and we register it before filing your CASP application. 100% foreign ownership is permitted. Every qualifying shareholder holding 10% or more undergoes fit-and-proper assessment, including source-of-funds verification, which we prepare with you. Corporate directors are not permitted. The statutory floor is a single director, but the Bank of Lithuania expects at least two persons effectively directing the business under the four-eyes principle.
Can an existing VASP registration be converted to a MiCA CASP licence?
No. Lithuania’s transitional period ended on 31 December 2025 and all legacy VASP registrations expired. There is no conversion mechanism: every entity must complete the full MiCA CASP authorisation procedure regardless of prior VASP status. From 1 January 2026, providing crypto-asset services without authorisation is a criminal offence carrying imprisonment for up to 4 years and fines up to €5,000,000 or 12.5% of annual turnover. We file the full application from scratch.
How long does it take to obtain authorisation?
4–8 months end-to-end: 2–6 weeks for formation and capital, 6–10 weeks while we build the compliance suite, up to 25 working days for the completeness check, and 40–60 working days for substantive assessment. The first Lithuanian CASP was authorised in roughly five months, so a well-prepared application reaches the lower end. Complex cases can run to 9–12 months. We run the schedule and keep the regulator’s clock moving.
Is the process conducted in English?
The Bank of Lithuania’s primary language is Lithuanian, though the CASP rules and key guidance are in English. Filing is through the LBIS portal and supporting documents are accepted with certified translations; reporting templates are Lithuanian-only. Our in-country specialists handle the Lithuanian-language filing and correspondence for you, so the language barrier is ours to manage, not yours.
Will you arrange banking for the licensed CASP?
Yes. MiCA Article 70 requires client funds to be held with a licensed credit institution, not an EMI, in a segregated account. We arrange both layers: an operational EMI account connected to CENTROlink for SEPA and TARGET2 access, and a credit-institution relationship for safeguarding. We start during the application so banking is ready when your licence is granted.
Does the licence cover tokenised securities or RWA?
No. MiCA Article 2(4) excludes crypto-assets that qualify as financial instruments. A tokenised security, share, bond or fund unit is regulated under MiFID II, the Prospectus Regulation and the EU DLT Pilot Regime, supervised by the Bank of Lithuania rather than under MiCA. Where your model needs it, we scope the securities route and pair it with crypto permissions or EU fund licensing.
Get a Lithuania crypto licence quote
We form your UAB, build the compliance suite, file with the Bank of Lithuania, obtain the licence and arrange banking. Tell us what you are building and we will map your route to approval and quote it.
Banking & Payments
A company and a licence still need a bank account
Banking is one of our three core services. We help high-risk and regulated businesses open the bank and payment accounts that others refuse: we work directly with EU EMIs, payment institutions and crypto-aware banks, confirm appetite before you apply, and make the introduction. Take it with your company and licence, or on its own.
Related Services
- Estonia CASP Licensing: MiCA authorisation with 0% CIT on retained profits
- Latvia CASP Licensing: cost-competitive MiCA authorisation in the Baltics
- Lithuania Company Formation: UAB registration for crypto and fintech businesses
- Crypto Business Banking: account opening for licensed operators